Corporate administrative liability: Model 231
The Italgas group has adopted an organization, management and control model, Model 231, for the prevention of crimes committed in the interest or to the advantage of the company. Italgas has also developed a specific training programme for the entire staff to ensure that it is applied effectively.
Legislative decree no. 231 of 8 June 2001 introduced the concept of Corporate Administrative Liability on the basis of which companies can be held liable and consequently sanctioned for some crimes attempted or actually committed in the interest or to the advantage of the company by its executives or employees. The company cannot be held liable if it adopted and effectively implemented an organization, management and control model capable of preventing such crimes and set up a Supervisory Body responsible for monitoring the operation of and compliance with the model before the crimes were committed.
Italgas and its subsidiaries have adopted their Model 231 for the prevention of crimes committed in the interest and to the advantage of the company and appointed a Supervisory Body with independent operational and control powers, in conformance with the legal provisions.
How administrative liability interacts with the Code of Ethics
The Italgas Code of Ethics establishes the business ethics principles that the company and its employees recognize, accept and promote. Model 231 is both a support tool and a central element of the Italgas Code of Ethics. The Supervisory Body and other control and monitoring mechanisms laid down in Model 231 are also fundamental elements of the Code of Ethics.
Model 231 is made up of a comprehensive set of principles, rules and provisions concerning the management and control of each company process. Great attention is paid by Italgas to the activities for implementing Model 231, with particular reference to the optimization of the corporate procedures, staff training and the implementation of specific control programmes.
The Italgas Model 231 represents a set of principles and the reference for elaborating the model of each of the subsidiaries. The Supervisory Body also acts as the Guarantor of the Code of Ethics with the task of promoting the implementation of the Code, its dissemination and the staff’s knowledge of it. The Guarantor is also responsible for examining reports of alleged violations of the Code of Ethics, and having the relevant investigations conducted.